Raanan Katz, RK Centers Adding Punitive Damages To The Claim

Raanan Katz, RK Centers are moving for punitive damages! Finally, Raanan Katz and RK Centers openly disclosed the amount they want to make from 10 count complaint. Oh là là ! Only 5 million dollars!?! Quelle catastrophe! Only 5 million dollars!?!

Here is the part of the punitive damages claim recently filed with Miami Court.

"Plaintiffs, R.K./FL MANAGEMENT, INC., R.K. ASSOCIATES VII, INC., 17070 COLLINS AVENUE SHOPPING CENTER, LTD., RAANAN KATZ, DANIEL KATZ, RK HALLANDALE 1, LLC, RK HALLANDALE LIMITED PARTNERSHIP, 18100 COLLINS AVENUE SHOPPING CENTER, LTD, RK 17600-17632 COLLINS, LLC, R.K.ASSOCIATES # 2, INC., R.K. ASSOCIATES XVIII, LLC, R K CAUSEWAY PLAZA, LLC, RK BISCAYNE PLAZA, LLC, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., RK SANS SOUCI PLAZA, LLC and RK SAGE PLAZA, LLC, hereby provide notice to this Court that Defendant continues to publish defamatory blogs that support Plaintiffs Motion for Leave to Amend Complaint to Add Claim for Punitive Damages (the "Motion for Punitive Damages"), and state as follows:...


"...b.    Saturday, April 20, 2013: "Raanan Katz: The Picture is Unfair, They Make Fun of Me" (the "April 20 Blog")

RAANAN KATZ AND LISPING ALAN KLUGER

Similarly, the April 20 Blog defames Plaintiffs as liars. In particular, one of the labels attached to the April 20 Blog is the word "pizdabol." According to the online Urban Dictionary, the term "pizdabol" means liar in Russian. See, Urban Dictionary, 'www.urbandictionwy.com/define.php?term=pizdabol.' Additionally, the April 20 Blog contains a threat against Plaintiff Raanan Katz personaLly: "(w)ell, no worries, Raanan, .. .the good one is coming.. and I mean not only picture..." A copy of the April 20 Blog is attached as Exhibit "B."..."

3.    The April 10 Blog and the April 20 Blog are false and defamatory per se because they accuse Plaintiffs of being liars. See Walsh v. Miami Herald Pub. Co., 80 So. 2d 669, 671 (Fla. 1955) (imputations of untruthfulness are considered actionable per se)...

See also Lawnwood Medical Center, Inc. v. Sadow, 43 So. 3d 710, 727 (Fla. 4th DCA 2010) (affirming $5 million dollar punitive damages award for defamation per se even where jury awarded no compensatory or nominal damages)."

This BS was respectfully submitted by Todd Levine (Raanan Katz and RK Centers attorney). Quel imbécile!

Raanan Katz: How To Spell, Don't Ask Me

This Raanan Katz, Miami Heat and RK Centers owner, publicly available deposition speaks for itself. Deposition of Raanan Katz was taken in his alleged copyright  case related to his "ugly picture". Enjoy!!!

RAANAN KATZ

In this part Raanan Katz admits "how much he paid" for allegedly purchased copyright work. Let's not forget that copyright means an intellectual, original works, no matter what Raanan Katz wishes...

"Raanan Katz: Okay. I -- no, again, I you know withdraw -- I offered him again a few dollars, he refuses to -refused to take it.
Attorney: You offered him a few dollars?
Raanan Katz: Yeah, only $500 to be exact, only $500 dollars. He said, "Raanan, I know that I caused you a damage, I apologize 100 times, you know. I'll send it to you -I  send it to you and I'll make sure that an act like this will ever happen again."
Attorney: Okay. Did you give him $500?
Raanan Katz: No, I said no. He refused to take it.
Attorney: Okay. Did you do that offer over the phone?
Raanan Katz: Yes.
Attorney: Did you ever email him an offer in writing?
Raanan Katz: No.
Attorney: Okay. It was only over the phone?
Raanan Katz: Only documents -- all these documents are drawn by Michael Chesal.
Attorney: All the documents are done by Michael Chesal?
Raanan Katz: You know, this only document or this only document was done -- was done by, there is no any other documents.
Attorney: It was prepared by your attorneys.
Raanan Katz: Yes.
Yeah, the guy named Johav Borowski.
Attorney: Johav Borowski?
Raanan Katz: Johav; how to spell, don't ask me.
Attorney: Okay. But he is the -- he doesn't list his name,
It just says Haaretz sports staff, on its article
Raanan Katz: Yeah, yeah.
Attorney: But that's who you believe is the author of the article?
Raanan Katz: Yes, that I believe.
Attorney: Okay. And though he and Mr. Magriso told you that that article was now removed from the Haaretz Newspaper and online edition?
Raanan Katz: Yes.
Attorney: Okay. Yet it's still on their website at least as of August 2nd, 2012 as shown in Exhibit 9?
Raanan Katz: Well, I -- I cannot tell you.
Attorney: Okay.
Raanan Katz: We were disappointed with this.
Attorney: Did you ever send any written demand to the Haaretz magazine to take it down?
Raanan Katz: No.
Attorney: Okay. Do you know how Haaretz ever got the image in the first place?
Raanan Katz: Just as testified before, Mr. Magriso took same picture in Jerusalem while I was falling off -- you I don't remember.
Attorney: Okay. And is it your intent to have a registration in the U.S. for your copyright for your image?
MR. KLUGER: Object to the form.
Raanan Katz: There is no need to do if she stops those -- this baloney what she is doing. As long -- as long when this -- this my case should be over, I don't need to do it -- I don't need to do it. Only reason we try to do it to make sure that -- that your client will stop using this nonsense, okay. And maybe you can or maybe you can put together, understand why should you explain her to stop this nonsense, because it doesn't do any good to anybody whatsoever. You know it, both they know it, she knows it and all my attorneys knows it.
Attorney: Okay. That was not responsive. Let's try the question again.
Raanan Katz: It's very responsive. Okay.
Attorney: Is it your intent to register this image with the U.S. copyright office?
Raanan Katz: I don't know what -- whatever my attorney will -will advise me that's what I'm going to do..."

RAANAN KATZ

I really like this Raanan Katz answer...

"Attorney: Okay. Are you aware that you stopped suing Google as well?
Raanan Katz: I am not that familiar about the dates. So, I cannot tell you exactly when and how. Only I tell you that nobody here is familiar about this atrocity case whatever it is and then -- and then, you know, again everyone tried to find what the right way because nobody understood how far your client will go this kind of nonsense and also this has surprised everybody. As I told you, she should get a life...

Attorney:Okay. And after number 4 there is a sentence that says, "All of these articles have the picture with my tongue out like Michael Jordan used to do when he drove to the basket."
Raanan Katz: Yes.
Attorney: Right?
Raanan Katz: Yes.
Attorney: Was it terrible that Michael Jordan had his tongue sticking out?
Raanan Katz: Obviously, this was not, but Michael Jordan has tongue sticking out only when he drive to the basket. This was his gesture but not for me I don't stand like a yoyo and had put my tongue out because anybody stand with the tongue out all the time go to, you know, to ame yaya.
Attorney: So it's a signature image tor Michael Jordan one of the most iconic basketball players in the entire world -
Raanan Katz: Uh-huh.
Attorney: But if you stick your tongue out it's a terrible horrible image?
Raanan Katz: Na, no, na, see now you don't -- now you try to trick me. Michael Jordan had his tongue out only sometimes when he drive to the basket, okay. That's a beautiful move, you know, he is not -- I bet he is the second best player because LeBron James is better than him (my comment: at this time I thought he would say his name, but...)-- better than him okay than he was. However, I know - however, it's a different story but Michael did never ever, ever stood in any place with those people and put his tongue out, okay. So you see you are trying to confuse it completely in a -- completely out. I was, I was falling off the steps there and I was
trying to hold myself and that why the tongue out and the photographer made a joke, all right. Your client took the joke and tried to fight me an this. Do you know how much time and money we spend an this? I just hope she paid you and does she pay your legal fee for, you know, tor all these atrocity?
Attorney: My deposition tor you, not your deposition tor me."
Complete details of Raanan Katz case can be downloaded on the federal court website.

Raanan Katz: The Picture Is Unfair, They Make Fun Of Me

Here is Raanan Katz deposition that was taken in his alleged copyright infringement case. To view all publicly available records, please, visit federal court website. For those who do not know Raanan Katz- Raanan Katz is RK Centers and Miami Heat Owner. He also likes suing people...

"DEPOSITION OF RAANAN KATZ

TAKEN ON BEHALF OF THE DEFENDANT

DECEMBER 18, 2012

11:06 a.m. - 4:59 p.m.

Raanan Katz: You know, again -- you know, I believe it took us sorne time to find who did it, took us some time to find, you know, who did it. And only reason I -- I did continue it I've to stop sort of saying, your client Start publishing this, you know, this article in the blogs and I saw everything what she did.

Attorney: Did you -

Raanan Katz: I didn’t have time, I left it alone.

Attorney: So, prior to the beginning publishing of blogs,

articies by my client, did you contact Mr. Seffi Magriso about this -- this photo?

Raanan Katz: Only -- only reason to contact him is because I saw the blog...if he dont have a blog I would've not have -- I would leave it alone, it's a joke...

Attorney: Okay.   The -- so, on that May -- on that May date; that was the first time that you decided that you wanted to go and contact Mr. Magriso?

Raanan Katz: I don't remember. I don't -- I cannot tell you I don't remember.

Attorney: Did you contact Seffi Magriso --

Raanan Katz: No.

Attorney:-- prior to seeing your picture on the defendant's blog? 

  

Raanan Katz: I don't think so.

Attorney: Okay.   So, earlier when you said that you got an email from your friend -

Raanan Katz:Mm-hmm.

Attorney:-- about the Haaretz -

Raanan Katz: Mm-hmm.

Attorney:-- article and you were upset about it -

Raanan Katz: Mm-hmm.

Attorney:-- you didn't contact the -- the photographer until you then later saw it on another publication?

Raanan Katz: No, I -

MR. KLUGER: Objection to -- object to the form. You can answer.

Raanan Katz: I called my friend -- I'm trying to remember. I told my friend to call the reporter not to the photographer.

Attorney: When did you tell your friend to call the reporter?

Raanan Katz: Some time after he sent me this article.

Attorney: After he sent you the article?

Raanan Katz: Yeah, from Haaretz.

Attorney: Was that before you saw the article, the photo, alleged photo in the -- in the blog?

Raanan Katz: I don't remember. She did a marvelous job is putting it nonstop, that's only what I looked like, okay, so.

Attorney: But you're not sure -

Raanan Katz: No -- no, you know, you know, let me answer please, okay. You know, here you see another picture in her one of her blogs. If she really want to be to be punk she could've had this, you know, this picture instead of, you know, this one, okay. So, let's say -- let's don't try to confuse me in some dates but go ahead...

Attorney: So, how -- how did you come to find this photo?

Raanan Katz: Sometimes somebody shows on the -- on the Internet and on the Internet, see I'm pretty popular, you know, in Israel. And it shows there and he sent me this. And I usually had just -- somebody had said me maybe I don't even say it at all. Right now, the only reason I now said, actually I never said it. Only reason it's here because your client decided to put it on you know to put it on it -- on her blogs to get those some ugly situation blogs.

Attorney: Okay. So, this photo here, a minute ago you said -this photo would have been okay to put in the blog article?

Raanan Katz: Yes, yes. Well, it's not to kept blog completely, because the blog is despicable -- make sure you understand what I'm saying, but if you -- if you da something, if you want to -- you can't let your life feel legit whatever it is, she could've put a good picture instead of this ugly pictures that everybody knows that this is certainly does look like me, look me underdressed, okay, that's what I'm saying.

Attorney: So -- so, the difference between this picture that we've been talking about and the other picture is that you believe the picture that's an issue in the case is ugly?

Raanan Katz: That the picture is unfair, they make fun of me.

Attorney: It makes fun of you?

Raanan Katz: And that's exactly what's her intention. To antagonize me, to help me in any way possible and to get me upset. That's exactly what's -- what's her full-- her cause and we can go to it later.

Attorney: Okay. So, if we put -- if she put this photo in an article about you that would be okay?

Raanan Katz: Nothing she do is okay, nothing, not a -- nothing she's doing -- she doing is disgrace to the human race, okay. Make sure you know you geb it; I'll say it in the court of law under -- under oath, okay, completely. But I say -- but at least, if she believe she want to make a point, and not to make a fool out of herself, she should have put picture like this or like this or many other pictures you can find on the -- on the Internet."

Well, no worries, Raanan, ...the good one is coming.. and I mean not only picture...

 

raanan katz

 

Raanan Katz v Google Inc Et Al Case

As Raanan Katz, RK Centers and Miami Heat Owner,  federal copyright case progresses (related to Raanan Katz picture), today I am publishing some new filings that now a part of public records and can be downloaded by members of the public.

So, here is the case #1:12-cv-22211-JLK, Raanan Katz v. Google Inc. et al, case , filed on Tuesday, June 12, 2012.

On March 11, 2013 Raanan Katz filed Motion to Strike the Affirmative Defenses to his Amended Complaint. In other words, Raanan Katz was trying to "elect" his favorite court strategy "Let me get DEFAULT"

On Friday, April 12, Response in Opposition to Plaintiff's (Raanan Katz) Motion to Strike Affirmative Defenses was filed and here are some key points.

"This is a frivolous copyright case, in which the Plaintiff (Raanan Katz) purports to have acquired the copyright to a photograph of the Plaintiff and alleges that the Defendant violated his copyright when she posted the photograph on her blog...

a. Unclean Hands (Affirmative Defense No. 4.)
Plaintiff (Raanan Katz) admitted at deposition that he allegedly acquired the copyright and brought this clam for purposes of causing Defendant to stop blogging about him. This was also admitted in a letter he wrote to the alleged photographer. Plaintiffs (Raanan Katz) not claiming that he lost any economic value of the photograph itself and has alleged no plans, much less the ability, to commercially exploit the photograph. Plaintiff (Raanan Katz) did not contact the alleged photographer to complain about the photograph until after he saw the photo in the blog, even though he had seen the photograph earlier on 'Haaretz.com.' (Ex. A, Katz Depo. at 83:12-16 - 84:1.) As Plaintiff (Raanan Katz) admitted at deposition, the "[o]nly reason we try to do it to make sure that - that [Defendant] will stop using this nonsense." (Ex. A, Katz Depo. at 150:9-15.)  He admitted that the "only reason" he contacted the photographer "is because I saw the blog ... If he don't have a blog, I would've not have —I would leave it alone, it's a joke." (Id. at 78:12-19.) Katz also wrote the alleged photographer that he wanted the assignment of copyright because his attorney is trying to legally eliminate the harassment by very bad Russian people." (Ex. B.) Even after 'Haaretz.com' published the photograph following the filing of this lawsuit, Plaintiff (Raanan Katz) never wrote it to demand that it be taken down. (Ex. A, Katz Depo. at 125:14-2 1.) Thus, the sole purpose of acquiring the copyright and bringing this action is to open another front in his (Raanan Katz) ongoing effort to shut down Defendant's blog...

g.    Misuse (Affirmative Defense No. 1)
Courts have held that copyright misuse can be found where the plaintiff seeks to leverage the copyright to undermine invention and creative expression. See Shloss v. Sweeney, 515 F. Supp. 2d 1068, 1080 (N.D. Cal. 2007). As discussed herein, this action is brought solely to suppress Defendant's blog. Plaintiff (Raanan Katz) admitted that he did not complain about the photo or seek to acquire the copyright until it was posted on Defendant's blog. As admitted in an email, Plaintiff sought to use the copyright to contest the blog, which he complained was published by "these Russians:" "My attorney is trying to legally eliminate the harassment by very bad Russian people and your cooperation will be appreciated. These Russians are posting the picture on their blog every week in order to embarrass me .. ." (Ex. B.) In other correspondence, Plaintiff (Raanan Katz) admitted that the blogs were "news publications." (Ex. C.) This improper leverage to suppress news about business and litigation practices is a proper basis for the misuse affirmative defense.

i.    Failure to Join (Affirmative Defense No. 6.)
This affirmative defense states that "Plaintiff has failed to join parties, including without limitation others claiming ownership of  alleged copyright or copyrights asserted by Plaintiff (Raanan Katz) in this action, which are necessary for a full and complete adjudication of its claims, including, without limitation, as required by Rule 19 of the Federal Rules of Civil Procedure . . ." (D.E. 28 at 5.) Because of questions of Plaintiff's ownership of the copyright, the failure to join the actual owner is fatal to Plaintiff's claim. Plaintiff (Raanan Katz) alleges that he obtained "all right, title and interest, including all rights of copyright" in the subject image by "assignment." (D.E. 10 at 2.) Plaintiff (Raanan Katz) claims to have obtained a written assignment of the copyright from a photographer. However, Plaintiff (Raanan Katz) has been unable to produce an original of the assignment and has not established that the alleged assignor owned the copyright. Plaintiff (Raanan Katz) claims that this photograph was published on the 'Haaretz.com' website, (Ex. C), and it may belong to that organization or another person or entity, other than the alleged assignor. Notably, 'Haaretz.com' continued to publish the photograph even after the alleged assignment. (Ex. A, Katz Depo. at 125:14-21.)

n.    Fraud (Affirmative Defense No. 11.)
The Fraud Affirmative Defense alleges that "Plaintiff knowingly procured the copyright(s) without authorization of the author and has misrepresented Plaintiff's rights." (D.E. 28 at 6.) Plaintiff claims that he acquired the copyright from the photographer, but no original of the assignment has been produced, and it has not been established that the alleged assignor is the actual owner of the copyright.

o.    Standing (Affirmative Defense No. 12.)
This affirmative  defense states "Plaintiff does not own a copyright to the photograph and has no standing to maintain this action.. . ." (D.E. 28 at 6-7.) Plaintiff (Raanan Katz) claims to have obtained the copyright from the photographer. Plaintiff has failed to produce an Original of the assignment agreement. Moreover, Plaintiff (Raanan Katz) failed to investigate whether the assignor was actually the copyright owner, if in fact he was the actual photographer. Notably, the photograph was originally publicized by 'Haaretz.com', but no assignment for 'Haaretz.com' has been produced. Nor has it been disclosed what the arrangement was between 'Haaretz.com' and the photographer regarding ownership of the copyright. Plaintiffs "must meet the statutory standing requirement contained in the Copyright Act of 1976, 17 U.S.C. § 501 (b), which provides that only the legal or beneficial owner of an 'exclusive right' has standing to bring a copyright infringement action in a United States court." Saregama India Ltd. v. Mosley, 635 F.3d 1284, 1290-91 (1 lth Cir. 2011). Plaintiff accordingly lacks standing to bring this claim.
IV.    Conclusion
This action is unambiguously another front in Plaintiffs (Raanan Katz) SLAPP litigation against an admitted news publication. Plaintiff (Raanan Katz) has suffered no harm other than thinking a photograph, in which he is well and appropriately clothed, somehow depicts him as underdressed. In Plaintiff's mind, the photograph is a 'joke." He acquired the copyright solely in an attempt to shut down the blog..."

raanan katz and alan kluger

How Raanan Katz, RK Centers Fabricate Their Pleadings

"он потянул ручки к бизнесу, ручки исчезли,бизнес остался..."

Here is the part of RK Centers and Raanan Katz pleadings based on which my identity was disclosed in Miami  State Court. After RK Centers and Raanan Katz have gotten what they wanted they simply amended the complaint removing the portion below.

"Defendant also published anti-Semitic depictions, including blog posts and cartoons, about Raanan Katz and Danny Katz, which tend to expose Plaintiffs to hatred, contempt, ridicule or obloquy. See copies of the anti-Sernitic blog posts and cartoons attached hereto as Exhibit "B." For instance, Defendant's anti-Semitic cartoon published on November 14, 2011 is comparable to the anti-Semitic cartoons attached hereto as Exhibit "C." Defendant's anti-Semitic publications, including the blog posts and cartoons"...by the way RK Centers and Raanan Katz attorney, Alan Kluger, presented to the court some type of cartoons that have never been published on the blog, intentionally misrepresenting the court in order to get WHAT RAANAN KATZ wants. Wow, what a fabricated liars.

By the way, do you know how Daniel (or they call him Danny) Katz called my husband ... "Russian F..... Jew".  

 

RK Centers, Raanan Katz New Lawsuit In Miami Court

According to Court records, RK Centers and Raanan Katz company, 17070 COLLINS AVE SHOPPING CENTER (LTD), initiated legal action for DAMAGES against former tenants located at 17100 Collins Ave., Sunny Isles Beach, FL 33160 case #2013-9648-CA-01.

RK Centers initiated legal action for DAMAGES on March 15, 2013, service was returned on March 18, 2013 for Defendant 01 and on March 22, 2013 for Defendants 02 and 03.

Now, the sign is posted on the premises by RK Centers that new business is coming. Does it mean RK Centers and Raanan Katz already signed a new lease? How long it takes for RK Centers to sign the lease since legal action for damages been initiated only on March 15?
Today is the due date for Defendant 01 to respond to RK Centers complaint.

How Raanan Katz and RK Centers expect tenant to pay rent if 17070 COLLINS AVE SHOPPING CENTER trespass customers from their tenants businesses, holding trespass order against John Doe(s).
I am curious how this claimed "DAMAGES" matter will be resolved...

RAANAN KATZ, RK CENTERS AND MIAMI HEAT OWNER

RK Centers, Raanan Katz Filed Concession Of Error In Appeal Court

This is the latest update in the appeal court in regards to preliminary injunction RK Centers, Raanan Katz, Daniel Katz, R.K./FL MANAGEMENT, INC., a Florida Corporation, R.K. ASSOCIATES VII, INC., a Florida Corporation, 17070 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RAANAN KATZ, an individual, DANIEL KATZ, an individual, RK HALLANDALE 1, LLC, a Florida Limited Liability Company, RK HALLANDALE LIMITED PARTNERSHIP, a Florida Limited Partnership, 18100 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RK 17600-17632 COLLINS, LLC, a Florida Limited Liability Company, R.K. ASSOCIATES # 2, INC., a Florida Corporation, R.K. ASSOCIATES XVIII, LLC, a Florida Limited Liability Company, R K CAUSEWAY PLAZA, LLC, a Florida Limited Liability Company, RK BISCAYNE PLAZA, LLC, an Oklahoma Limited Liability Company, CALIFORNIA CLUB MALL SHOPPING CENTER, LTD., a Florida Limited Partnership, RK SANS SOUCI PLAZA, LLC, a Florida Limited Liability Company, and RK SAGE PLAZA, LLC, a Florida Limited Liability Company,  somehow obtained in Miami State Court.

Alan Kluger and Todd Levine of Miami based Kluger, Kaplan, Katzen, Silverman, Levine Law firm helped rich and famous RK Centers and Raanan Katz to obtain unlawful injunction. 

Here is the extraction of the Concession of Error filed IN THE DISTRICT COURT OF APPEAL OF FLORIDA THIRD DISTRICT CASE NO. 3D12-3221 by RK Centers and Raanan Katz.

"CONCESSION OF ERROR
In this appeal, the appellant challenges a preliminary injunction. In one of the grounds raised, the appellant argues that he was not provided with actual notice until after the hearing on the preliminary injunction and after the issuance of the preliminary injunction, and that the injunction did not meet the requirements of Fla. R. Civ. P. 1.610(a)(1)(A) and (B) for dispensing with such notice. See Initial Brief of Appellant at 9-12 (section "A" entitled "The Injunction. Failed to Satisfy Florida Rules of Civil Procediure 1.610"). Upon review of the record, the appellees (RK Centers, Raanan Katz, Daniel Katz) concede that this argument is correct.
Accordingly, based upon this argument alone, the appellees (RK Centers, Raanan Katz, Daniel Katz) concede error and agree to reversal and remand with directions to vacate the preliminary injunction..."

I will not comment on this matter at this time due to the pending decision of the appeal court.

Just remember these names
RK Centers, Raanan Katz, Daniel Katz, R.K./FL MANAGEMENT, INC., a Florida
Corporation, R.K. ASSOCIATES VII, INC., a Florida Corporation, 17070 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RAANAN
KATZ, an individual, DANIEL KATZ, an individual, RK HALLANDALE 1, LLC, a Florida Limited Liability Company, RK HALLANDALE LIMITED PARTNERSHIP,
a Florida Limited Partnership, 18100 COLLINS AVENUE SHOPPING CENTER, LTD., a Florida Limited Partnership, RK 17600-17632 COLLINS, LLC, a Florida
Limited Liability Company, R.K. ASSOCIATES # 2, INC., a Florida Corporation, R.K. ASSOCIATES XVIII, LLC, a Florida Limited Liability Company, R K CAUSEWAY
PLAZA, LLC, a Florida Limited Liability Company, RK BISCAYNE PLAZA, LLC, an Oklahoma Limited Liability Company, CALIFORNIA CLUB MALL SHOPPING
CENTER, LTD., a Florida Limited Partnership, RK SANS SOUCI PLAZA, LLC, a Florida Limited Liability Company, and RK SAGE PLAZA, LLC, a Florida Limited Liability Company.

RAANAN KATZ